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THE BLOMBERG LAW FIRM LLC
1087 Broad Street + Second Ploor
Bridgeport, Connecticut 06604
‘Tel: (203) 908-4010 * Fax: (203) 908-4008
Juris Number 437017
RETURN DATE: MAY 7, 2019 : SUPERIOR COURT
ESDRA L. ESCOBAR AGUILAR; 2 J.D, OF FAIRFIELD
ESDRA L. ESCOBAR AGUILAR :
PPA DYLAN PAREDES
AT BRIDGEPORT
Vv.
TYRONE C. ROBINSON; : MARCH 22, 2019
COMPLAINT
FIRST COUNT (ESDRA L. ESCOBAR AGUILAR):
1, The minor-plaintiff, DYLAN PAREDES, is a minor and brings this action
through his mother, next friend and legal guardian, ESDRA L. ESCOBAR AGUILAR.
2. On or about March 28, 2017, approximately 8:19 am, the plaintiff, ESDRA L.
ESCOBAR AGUILAR, was operating a 2004 Toyota motor vehicle in a northerly direction on
225 High Ridge Road in Stamford, Connecticut.
3. At said time, plaintiff, the minor-plaintiff, DYLAN PAREDES, was a passenger
in said 2004 Toyota motor vehicle.
4. At said time, the defendant, TYRONE C. ROBINSON, was operating a 2005
Toyota motor vehicle in a northerly direction on 225 High Ridge Road in Stamford, Connecticut.
5. At all times relevant hereto, the defendant, TYRONE C. ROBINSON, owned said
2005 Toyota motor vehicle.THE BLOMBERG LAW FIRM LLC
1087 Broad Street * Second Floor
Bridgeport, Connecticut 06604
‘Tel: (203) 908-4020 © Fax: (203) 908-4008
Juris Number 437017,
6. At said time, the defendant, TYRONE C. ROBINSON, struck a motor vehicle and
said vehicle struck the rear end of plaintiff's motor vehicle.
7. As a direct result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR
AGUILAR, sustained injuries and damages.
8. The aforesaid collision was caused by the negligence and/or carelessness of the
defendant, TYRONE C, ROBINSON, in one or more the following respects:
(a) In that he failed to operate his motor vehicle a reasonable distance apart from
other motor vehicles in violation of Connecticut General Statutes Section 14-240;
(b) In that he failed to operate his motor vehicle at a reasonable speed in light of the
weather conditions and highway traffic in violation of Connecticut General Statutes
Section 14-21 8a;
{c) In that he failed to maintain a proper lookout;
(d) In that he failed to maintain control of his motor vehicle;
(e) In that he failed to timely brake his motor vehicle;
@) In that he failed to timely turn his motor vehicle to avoid said collision; and
(g) In that he failed to operate his motor vehicle at a reasonable distance from other
vehicles on the highway.THE BLOMBERG LAW FIRM LLC
1087 Broad Street * Second Floor
Bridgeport, Connecticut 06604
Tel: (203) 908-4010 * Fax: (203) 908-4008
Juris Number 437017
9.
Asa direct result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR
AGUILAR, sustained the following painful, severe and/or permanent injuries:
(a)
(b)
©)
@)
(e)
©
()
(h)
@
10.
Cervical sprain/strain;
Cervical radiculitis;
Cervicalgia;
Concussion Syndrome;
Cervical C5/6, C6/7, C3/4 and C4/5 disc herniation;
Restricted range of motion to the T4-T6 levels;
Lumbar sprain/strain;
Lumbalgia; and
Thoracic sprain/strain.
As a further result of said collision, the plaintiff, ESDRA L. ESCOBAR
AGUILAR, sustained a permanent injury to her cervical spine.
11.
As a further result of said collision, the plaintiff, ESDRA L. ESCOBAR
AGUILAR, sustained a permanent impairment due to post concussion migraine headaches.
12.
As a further result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR
AGUILAR, has been required to expend and/or may be required to expend money for medicalTHE BLOMBERG LAW FIRM LLC
1087 Broad Street * Second Floor
Bridgeport, Connecticut 06604
‘Tel: (203) 908-4010 © Fax: (203) 908-4008.
Juris Number 437017
treatment, hospitalization, surgery, x-rays and other diagnostic tests, medical care and treatment,
chiropractic care and treatment, and medication all to her financial loss.
13. As a further result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR
AGUILAR, has and will continue to suffer physical, mental, and emotional pain and anguish,
and she has been and/or will be sick, sore and/or disabled for a long period of time.
14. Asa further result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR
AGUILAR, has sustained a permanent impairment of her ability to engage and/or enjoy life’s
activities.
15. Asa further result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR
AGUILAR, has incurred lost wages and has sustained a loss of earning capacity.
SECOND COUNT (ESDRA L. ESCOBAR AGUILAR
PPA DYLAN PAREDES):
1-6. Paragraphs 1 through 6 of the First Count are hereby fully incorporated herein and
made Paragraphs 1 through 6 of the Second Count.
7. As a direct result of the aforesaid collision, the minor-plaintiff, DYLAN
PAREDES, sustained injuries and damages.THE BLOMBERG LAW FIRM LLC
1087 Broad Street ¢ Second Floor
Bridgeport, Connecticut 06604
Tel: (203) 908-4010 + Fax: (203) 908-4008
Juris Number 437017
9. As a direct result of the aforesaid collision, the minor-plaintiff, DYLAN
PAREDES, sustained physical and emotional trauma.
10. As a further result of the aforesaid collision, the minor-plaintiff, DYLAN
PAREDES, has been required to expend and/or may be required to expend money for medical
treatment, hospitalization, surgery, x-rays and other diagnostic tests, medical care and treatment,
chiropractic care and treatment, and medication all to his financial loss.
i. As a further result of the aforesaid collision, the minor-plaintiff, DYLAN
PAREDES, has and will continue to suffer physical, mental, and emotional pain and anguish,
and he has been and/or will be sick, sore and/or disabled for a long period of time.
12. As a further result of the aforesaid collision, the minor-plaintiff, DYLAN
PAREDES, has sustained a permanent impairment of his ability to engage and/or enjoy life’s
activities.
THE PLAINTIFF,
» Se
ERIC G. BLOMBERG
THE BLOMBERG LAW FIRM, LLC
1087 Broad Street, Second Floor
T: (203) 908-4010; F: (203) 908-4008
Juris #437017
eblomberg@blomberglaw.com
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THE BLOMBERG LAW FIRM LLC 1087 Broad Street + Second Ploor Bridgeport, Connecticut 06604 ‘Tel: (203) 908-4010 * Fax: (203) 908-4008 Juris Number 437017 RETURN DATE: MAY 7, 2019 : SUPERIOR COURT ESDRA L. ESCOBAR AGUILAR; 2 J.D, OF FAIRFIELD ESDRA L. ESCOBAR AGUILAR : PPA DYLAN PAREDES AT BRIDGEPORT Vv. TYRONE C. ROBINSON; : MARCH 22, 2019 COMPLAINT FIRST COUNT (ESDRA L. ESCOBAR AGUILAR): 1, The minor-plaintiff, DYLAN PAREDES, is a minor and brings this action through his mother, next friend and legal guardian, ESDRA L. ESCOBAR AGUILAR. 2. On or about March 28, 2017, approximately 8:19 am, the plaintiff, ESDRA L. ESCOBAR AGUILAR, was operating a 2004 Toyota motor vehicle in a northerly direction on 225 High Ridge Road in Stamford, Connecticut. 3. At said time, plaintiff, the minor-plaintiff, DYLAN PAREDES, was a passenger in said 2004 Toyota motor vehicle. 4. At said time, the defendant, TYRONE C. ROBINSON, was operating a 2005 Toyota motor vehicle in a northerly direction on 225 High Ridge Road in Stamford, Connecticut. 5. At all times relevant hereto, the defendant, TYRONE C. ROBINSON, owned said 2005 Toyota motor vehicle.THE BLOMBERG LAW FIRM LLC 1087 Broad Street * Second Floor Bridgeport, Connecticut 06604 ‘Tel: (203) 908-4020 © Fax: (203) 908-4008 Juris Number 437017, 6. At said time, the defendant, TYRONE C. ROBINSON, struck a motor vehicle and said vehicle struck the rear end of plaintiff's motor vehicle. 7. As a direct result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR AGUILAR, sustained injuries and damages. 8. The aforesaid collision was caused by the negligence and/or carelessness of the defendant, TYRONE C, ROBINSON, in one or more the following respects: (a) In that he failed to operate his motor vehicle a reasonable distance apart from other motor vehicles in violation of Connecticut General Statutes Section 14-240; (b) In that he failed to operate his motor vehicle at a reasonable speed in light of the weather conditions and highway traffic in violation of Connecticut General Statutes Section 14-21 8a; {c) In that he failed to maintain a proper lookout; (d) In that he failed to maintain control of his motor vehicle; (e) In that he failed to timely brake his motor vehicle; @) In that he failed to timely turn his motor vehicle to avoid said collision; and (g) In that he failed to operate his motor vehicle at a reasonable distance from other vehicles on the highway.THE BLOMBERG LAW FIRM LLC 1087 Broad Street * Second Floor Bridgeport, Connecticut 06604 Tel: (203) 908-4010 * Fax: (203) 908-4008 Juris Number 437017 9. Asa direct result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR AGUILAR, sustained the following painful, severe and/or permanent injuries: (a) (b) ©) @) (e) © () (h) @ 10. Cervical sprain/strain; Cervical radiculitis; Cervicalgia; Concussion Syndrome; Cervical C5/6, C6/7, C3/4 and C4/5 disc herniation; Restricted range of motion to the T4-T6 levels; Lumbar sprain/strain; Lumbalgia; and Thoracic sprain/strain. As a further result of said collision, the plaintiff, ESDRA L. ESCOBAR AGUILAR, sustained a permanent injury to her cervical spine. 11. As a further result of said collision, the plaintiff, ESDRA L. ESCOBAR AGUILAR, sustained a permanent impairment due to post concussion migraine headaches. 12. As a further result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR AGUILAR, has been required to expend and/or may be required to expend money for medicalTHE BLOMBERG LAW FIRM LLC 1087 Broad Street * Second Floor Bridgeport, Connecticut 06604 ‘Tel: (203) 908-4010 © Fax: (203) 908-4008. Juris Number 437017 treatment, hospitalization, surgery, x-rays and other diagnostic tests, medical care and treatment, chiropractic care and treatment, and medication all to her financial loss. 13. As a further result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR AGUILAR, has and will continue to suffer physical, mental, and emotional pain and anguish, and she has been and/or will be sick, sore and/or disabled for a long period of time. 14. Asa further result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR AGUILAR, has sustained a permanent impairment of her ability to engage and/or enjoy life’s activities. 15. Asa further result of the aforesaid collision, the plaintiff, ESDRA L. ESCOBAR AGUILAR, has incurred lost wages and has sustained a loss of earning capacity. SECOND COUNT (ESDRA L. ESCOBAR AGUILAR PPA DYLAN PAREDES): 1-6. Paragraphs 1 through 6 of the First Count are hereby fully incorporated herein and made Paragraphs 1 through 6 of the Second Count. 7. As a direct result of the aforesaid collision, the minor-plaintiff, DYLAN PAREDES, sustained injuries and damages.THE BLOMBERG LAW FIRM LLC 1087 Broad Street ¢ Second Floor Bridgeport, Connecticut 06604 Tel: (203) 908-4010 + Fax: (203) 908-4008 Juris Number 437017 9. As a direct result of the aforesaid collision, the minor-plaintiff, DYLAN PAREDES, sustained physical and emotional trauma. 10. As a further result of the aforesaid collision, the minor-plaintiff, DYLAN PAREDES, has been required to expend and/or may be required to expend money for medical treatment, hospitalization, surgery, x-rays and other diagnostic tests, medical care and treatment, chiropractic care and treatment, and medication all to his financial loss. i. As a further result of the aforesaid collision, the minor-plaintiff, DYLAN PAREDES, has and will continue to suffer physical, mental, and emotional pain and anguish, and he has been and/or will be sick, sore and/or disabled for a long period of time. 12. As a further result of the aforesaid collision, the minor-plaintiff, DYLAN PAREDES, has sustained a permanent impairment of his ability to engage and/or enjoy life’s activities. THE PLAINTIFF, » Se ERIC G. BLOMBERG THE BLOMBERG LAW FIRM, LLC 1087 Broad Street, Second Floor T: (203) 908-4010; F: (203) 908-4008 Juris #437017 eblomberg@blomberglaw.com